6 replies to this topic

[ymorgad]

Hi everybody,

 

I have a question regarding internal audits under the new BRC Packaging standard (Version 7), specifically clause 3.5.1:

 

"There shall be a scheduled programme of internal audits spread throughout the year."

 

Does this mean we should schedule internal audits on multiple dates? I was considering conducting audits twice a year, spaced 6 months apart (covering half of the BRC requirements in each audit). Is this the correct approach, or should we follow a different schedule?

 

Thanks in advance

[GMO]

Does this mean we should schedule internal audits on multiple dates? 

 

Yes it does mean you should schedule them on multiple dates throughout the year.

 

 

 I was considering conducting audits twice a year, spaced 6 months apart (covering half of the BRC requirements in each audit). Is this the correct approach, or should we follow a different schedule?

 

I wouldn't do that personally.  Actual auditors may have a clearer view but the auditors I've seen have generally expected to see these things (in the food standard):

 

• Frequency is based on risk.  This will mean that some areas might be audited more than once a year.  You should have a risk assessment for how often you audit different parts of the FSQMS and that will be influenced on risk and how much they're reviewed in other ways (e.g. through GMP / facility inspections).
• Auditors assigned should be independent of the processes.
• Then I'd still expect audits planned throughout the year and given sufficient time.  That way you can go into depth and any actions raised are not a crazy number for the team.

 

Auditing on two days of the year suggests you've not done the above can anyone be truly independent of half a standard unless they're a contractor?  Are you giving them enough time?  How can you say it's based on risk if you're arbitrarily splitting it in two?  So I'd have a rethink.  Looking at the packaging standard it does say in section 3.5 "spread throughout the year" and "in relation to risk" and also asks for auditor independence.  So while my experience is with the food standard, I'm imagining they'd be asking for similar.

[ymorgad]

Hi,

 

Thank you for your quick response! I agree with your points.

 

Previously, under BRC Packaging Version 6, we scheduled internal audits once a year based on our risk analysis (which considered past audit results and inspections). We allocated 2 full days for the audit, during which the auditor covered all requirements.

 

Now, with Version 7’s Clause 3.5.1 requiring audits to be "spread throughout the year," how should we adjust?

 

Should we split the audit into two separate sessions (1 day each, 6 months apart), covering different processes in each session?

 

N.B: Our risk analysis still suggests an annual frequency.

 

 

Thanks again!

[GMO]

 

Hi,

 

Thank you for your quick response! I agree with your points.

 

Previously, under BRC Packaging Version 6, we scheduled internal audits once a year based on our risk analysis (which considered past audit results and inspections). We allocated 2 full days for the audit, during which the auditor covered all requirements.

 

Now, with Version 7’s Clause 3.5.1 requiring audits to be "spread throughout the year," how should we adjust?

 

Should we split the audit into two separate sessions (1 day each, 6 months apart), covering different processes in each session?

 

N.B: Our risk analysis still suggests an annual frequency.

 

 

Thanks again!

 

 

As I said before, throughout the year suggests more than 2 days.  Remember audits are normally part of your HACCP verification so to only have indicators of that twice a year isn't good practice.  

 

Why does your risk assessment suggest annual frequency for everything?  That seems odd.  So you're saying that the risk of pest management having an issue is the same as HACCP is the same as allergen control?  Really?  That seems unlikely.  What is the basis of your risk assessment?  Have you tried to produce a once a year outcome?

 

Either way, I'd spread it out over the year.  Once a quarter minimum.  But I'd also audit sections of the standard separately so they can get full attention.  2 days of internal auditing in a year is nothing.  It's ticking a box.  Ten times that amount is not unreasonable.

 

Do you really want to find internal non conformity and improve your FSQMS, potentially picking up early indicators of HACCP failure or just do what's needed for the audit?  If you just want to tick the box for the audit, you might get away with two days but as I've explained twice now, that's hardly in the spirit of the clause an auditor will probably pick up on it.  Yet you've now asked the same question twice.  Hoping for a different answer perhaps?  Why?  Do you value internal auditing?

[Tony-C]

Hi ymorgad,

 

I agree with GMO's posts   ​  

 

‘spread throughout the year’ was added to clause 3.5.1 in BRCGS Global Standard for Packaging Materials Issue 7 and so auditors will be looking to ensure that you have taken that into consideration.

 

You may get away with 2 audit dates for now but I would change to 4 audit dates as per the food standard: ‘at least four different audit dates spread throughout the year’. This allows some room for you to also demonstrate you have considered: ‘The frequency at which each activity is audited shall be established in relation to the risks associated with the activity and previous audit performance.’

 

Kind regards,

 

Tony

 

[jfrey123]

As a youngin' I tried selling the auditors that my company reviewed our entire FSQMS with the owners to the audit standard once per year.  If you can actually review your entire book, not just that it meets standard but that each program meets the objectives you intend it to satisfy internally, then more power to you...

 

But with my experience now, break that thing into chunks and review it more often.

[ymorgad]

Thank you all for your helpful responses! Your insights gave me exactly the guidance I needed.